Phased developments need phased BNG planning

Phased developments need phased BNG planning

18 Oct 2024 | 5 min read

As large developers create plans for 10% biodiversity net gain for local planning authority (LPA) approval they have another caveat to keep in mind: phased developments need phased BNG planning.

The UK Government in early October released templates for phased development to be provided to LPAs. The following is a quick overview of what those new templates entail for developers and ecologists.

Your Overall Biodiversity Net Gain plan is a given

As is required by the UK’s Environment Act 2021, when LPAs have approved initial planning applications, developers must submit a full Overall Biodiversity Gain Plan to LPAs for all projects. The government specifies that the Overall Biodiversity Gain Plan template be used to create the overall plan.

Through this template you will show how your development will meet the 10% BNG requirement. You cannot proceed until the LPA approves the plan and your calculations using the Defra Statutory Biodiversity Metric calculation tool.

The government recognizes that large projects may need to be developed over a long period of time with a phased approach. It is important that you engage with your LPA about BNG requirements prior to creating a biodiversity planning application to ensure you have permission to proceed with a phased approach to your development. When you receive the decision notice that affirms permission you can proceed with biodiversity gain planning.

Your Overall Biodiversity Gain Plan can assure authorities that you have a clear approach to meeting 10% BNG requirements for the full project. But you will also be required to submit a Phase Biodiversity Net Gain Plan to assure that each phase will contribute to the overall 10% BNG commitment.

What phased developments add to BNG process

As mentioned, as of October 10, 2024, the UK government requires that a separate BNG plan — Phase Biodiversity Gain Plan — be submitted outside of the overall BNG plan for each phase of a multi-phase development project. The government has provided a separate form for phased developments, which you can complete for each phase and submit to your LPA for approval to begin work.

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With each Phase Biodiversity Gain Plan, you present how you will progress toward delivering on your project’s full BNG strategy and objectives during the specific phase of work.

General requirements of the plan include:

Accounting of post-development biodiversity value

Your LPA will want to get a clear picture of how you will be delivering Biodiversity Net Gain: How will you balance on-site and off-site gains? Will you use biodiversity credits? Will you take a phased approach to on-site enhancements? Will your plans require s106 agreements?

In addition to supplying the above information, you will need to:

  • Determine on-site habitat biodiversity value not just for the specific phase. Show the estimated value for all project phases, whether they have been completed or are still in planning stages.
  • Show any registered off-site biodiversity gain relevant to the entire development, both existing and proposed.
  • List any biodiversity credits you purchased before submitting the phase plan or plan to secure for the entire development.

Standard and additional Information and descriptions

  • Supply name and address of the plan’s author and submitter.
  • Describe the development and relevant planning permission details.
  • Provide detailed post-development plans showing existing on-site habitats, including irreplaceable ones, with scale and orientation.
  • Include completed biodiversity metric calculations, comprising pre- and post-development values.
  • Show planned steps to minimize adverse effects on on-site biodiversity.
  • Explain how you will maintain and monitor habitat enhancements.
  • Describe adherence to the Biodiversity Gain Hierarchy, and provide justifications for any deviations.
  • Clarify any involvement with irreplaceable habitats and show compensation arrangements for any impacts.

Checklist before starting development work

Before commencing work on a large, phased-development project, you must be sure:

  • You have received planning permission from your LPA.
  • You have submitted two plans to your LPA:
    • Your Overall Biodiversity Gain Plan.
    • You first Phase Biodiversity Gain Plan.
  • You have received LPA approval for your BNG plans.

Keep in mind that every phase will require its own Phase Biodiversity Gain Plan before work can begin.

The scope of the Phase Biodiversity Gain Plan is clearly more narrow than the Overall Biodiversity Gain Plan. However, it serves to keep each phase of your project on track to deliver its own progress to your BNG goal for your entire development.

For more information

Review full government guidance and details of the Phase Biodiversity Gain Plan.

Access Overall Biodiversity Gain Plan template.

Access Phase Biodiversity Gain Plan template.

Get more information on how AiDash BNGAI can streamline your BNG planning, including overall and phase plans.